NOVI CONNECT, INC.

PRIVACY POLICY

Last modified:  May 15, 2021

Novi Connect, Inc. (“Novi,” “we,” “us,” or “our”) respects your privacy and we are committed to protecting it through our compliance with this Privacy Policy (the “Policy”). In order to provide you with access to our proprietary technology platform that helps companies evaluate the raw materials in their products (the “Services”), we collect and use information about you, our:

  • Brands – businesses who make the products for which they wish to access our Services
  • Retailers – businesses that sell the products to the public for use or consumption
  • Suppliers – businesses who supply ingredients
  • Authorized Users – individuals or affiliates approved by Brands, Retailers, or Suppliers to access the Services

This Policy describes the types of information we may collect from you or that you may provide when you visit our website https://noviconnect.com/ (our “Website”) or use our Services, and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Policy applies to information we collect:

  • On our Website.
  • In e-mail and other electronic messages between you and us.
  • When you use our Services.

It does not apply to information collected by:

  • use offline or through any other means, including on any other website operated by us or any third party (including our affiliates and subsidiaries); or
  • any third party, including through any application or content (including advertising) that may link to or be accessible from our Website.

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website and Services. By accessing or using our Website and/or Services you agree to this Policy.

This Policy is part of the agreement that we may have entered with you, such as Terms of Service for Brands, Master Services Agreement, or a Nondisclosure Agreement (the “Agreement”). Any term not defined herein will have the same meaning as ascribed to it as the Agreement. From time to time, we reserve the right to modify or amend the terms of our Policy. You will be notified of such changes by notifications on our Website, by e-mail notification informing you of such changes, or by any other reasonable means as required by applicable law. You should check this Policy frequently for any changes. Your continued use of our Website, and/or our Services following the posting of changes to this Policy will mean that you accept those changes.

BY ACCESSING OUR WEBSITE OR BY USING OUR SERVICES, YOU AGREE TO AND ACCEPT THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS OUR WEBSITE OR OUR SERVICES.

1. Territorial Scope

Our Website and/or Services are available for use globally.

2. Minors and Children Under the Age of 13

Our Website and Services are not intended for minors and children under age 18. Further, we do not knowingly collect personal information from children under age 13. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at privacy@noviconnect.com.

3. Information We Collect About You

We collect Personal Information (defined below) and information that is not Personal Information (“Non-Personal Information,” together with Personal Information, “Information”) regarding users of the Services or relating to the Services, either directly or through the activities of third-party suppliers and/or service providers. For purposes of this Policy, “Personal Information” means the information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a person. We may combine Non-Personal Information with Personal Information, and in those circumstances we will treat the combined information as Personal Information. We collect several types of Personal Information from and about users of our Website, App, and/or Services, including the following information:

  • First and last name
  • Email address
  • Name of the Employer
  • Job Title

4. How We Collect Your Information

We collect your information from various sources that may include, for example, from:

  • You Directly. Information you provide directly when you use or otherwise interact with our Website or Services, or establish an account.
  • Your Browser or Device. Information collected automatically as a result of your interaction with us, and/or use of the Services (including information we receive when you use your loyalty card(s), historical sales information your geolocation information (which may include specific longitude and latitude), usage times and volume, and information about the device you are using (for example, device type, device ID, characteristics and status, browser type, operating system and application version and information about how our application is used) or through our marketing activities. We use Google Analytics to collect such data. Terms of Service for Google Analytics are available here: https://www.google.com/analytics/terms/us.html.

We may also use cookies to collect the above information.  Cookies are small files of letters and numbers stored on your browser or device that enable the cookie owner to recognize the device when it visits websites or uses online services. The website you visit may set cookies directly, known as first-party cookies, or may trigger cookies set by other domain names, known as third-party cookies. While we may automatically use some cookies that are strictly necessary to provide the services you request or enable communications, we request your consent for all of our other cookie uses.

We may use the following types of cookies:

  • Analytical/performance cookies. These cookies allow us and our third-party service providers to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us improve how our website works by, for example, ensuring that users can easily find what they need on our website. These cookies generate aggregate statistics that are not associated with an individualized profile, and are both session cookies, which expire once you close your web browser, and persistent cookies, which stay on your computer until you delete them.
  • Functionality cookies. These cookies enable helpful but non-essential website functions that improve your website experience. By recognizing you when you return to our website, they may, for example, allow us to personalize our content for you, greet you by name, or remember your preferences. These cookies generate aggregate statistics that are not associated with an individualized profile, and are both session cookies, which expire once you close your web browser, and persistent cookies, which stay on your computer until you delete them.

Except for strictly necessary cookies, all first-party cookies set by this website will expire when you block or delete these cookies. Third-party cookie expiration periods are set by their respective owners.

  • Third Parties. Information we collect about you from third parties, such as your employer, if the account is created by an Authorized User.
  • Otherwise in accordance with our Agreement with you. Information as described elsewhere in this Policy, Agreement, and/or applicable terms, or at the time such information is collected.

5. How We Use Your Information

We use information that we collect about you or that you provide to us, including any Personal Information:

  • To provide Services.
  • To obtain, maintain, and improve our Website and Services.
  • To provide you with information on the Services as requested by you.
  • To notify you about changes to our Website or any Services we offer or provide through it.
  • To help create your profile.
  • To improve customer experience.
  • Provide customer support.

6. Disclosure of Your Information

We may disclose aggregated information about our users and information that does not identify any individual, without restriction.

We may disclose Personal Information that we collect, or you provide as described in this Policy:

  • To our employees on a need to know basis.
  • In anonymized and/or aggregated form to contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Information held by us about our Website users is among the assets transferred.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.

We may also disclose your Personal Information:

  • To comply with any court order, law or legal process, including to respond to any government or regulatory request.
  • To enforce or apply our terms of use, and other agreements, including for billing and collection purposes.
  • If we believe disclosure is necessary or appropriate to protect our rights, property, or safety, or the rights, property, or safety of our customers or others.

7. Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the information you provide to us. We have created mechanisms to provide you with the following control over your information:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this Website may then be inaccessible or not function properly.
  • Do Not Track.  Do Not Track is a privacy preference that can be set in web browsers. Our Website recognizes do not track browser settings or signals. For information about do not track, please visit https://allaboutdnt.com/.
  • Disclosure of Your Information for Third-Party Advertising.  We do not sell, trade, or otherwise transfer your Personal Information unless we provide you with advance notice. However, this does not include website hosting partners and other third parties who assist us in operating our Website, conducting our business, or servicing, so long as those parties agree to keep your information confidential.
  • We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI's website.

8. Third Party Links On Our Website

Our Website may contain links to other third party websites for your convenience. We are not responsible for the privacy policies and practices of other third parties and any information you submit to a third party is subject to their privacy policy. Once you leave our Website, or are redirected to a third-party website, application, or other online service, we encourage you to read the privacy policy applicable to that third party.

9. Account Deletion

Upon termination or expiration of the Agreement, your account will be deleted in accordance with the Agreement.  However, if you wish to delete the account during the term of the Agreement, please contact the Brand/Supplier, whose Authorized Users you are for such deletion request. We will process the account deletion request from the Brand/Supplier, as applicable, without any undue delay.

10. Opt-Out of Communications with Novi

  • E-mail Contact. You may opt-out of receiving promotional e-mail communication from us by sending us an e-mail at privacy@noviconnect.com. Please note that you will not be able to opt-out of transactional e-mail communication, such as communication related to your account.
  • Push Notification. You can opt out of receiving push notifications through your device settings. Please note that opting out of receiving push notifications may impact your use of the Website and/or Services.

11. Your California Privacy Rights

We do not sell, trade, or otherwise transfer to outside third parties your Personal Information. California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to privacy@noviconnect.com.

Further, the California Consumer Privacy Act of 2018, as amended (Cal. Civ. Code §§ 1798.100 to 1798.199) (“CCPA”), does not apply to us. If you have any questions or concerns about the CCPA or its non-applicability to us, please do not hesitate to e-mail us at privacy@noviconnect.com.

12. Data Processing and Security

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us is stored on our secure servers behind firewalls.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, by encrypting data in transit, we cannot guarantee the security of your Personal Information transmitted to our Website. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Data that you provide is hosted on dedicated servers of our third-party partners.

13. Changes to Our Privacy Policy

It is our policy to post any changes we make to our Privacy Policy on this page, or by sending you an e-mail notification, or any other method prescribed under applicable law. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring that we have your up-to-date active and deliverable email address, and for periodically visiting our Website and this Privacy Policy to check for any changes.

14. Contact Information

To ask questions or comment about this Privacy Policy and our privacy practices, contact us at: privacy@noviconnect.com

OR

Novi Connect, Inc.

700 Larkspur Lane, Suite 199

Larkspur CA, 94939

PLEASE NOTE: IF YOU USE OUR WEBSITE AND/OR OUR SERVICES, YOU HAVE AGREED TO AND ACCEPTED THE PRACTICES DESCRIBED IN THIS POLICY. IF YOU DO NOT AGREE WITH THE TERMS OF THIS POLICY OR THE AGREEMENT, PLEASE DO NOT USE OUR WEBSITE OR SERVICES.